Last revised August 2023
What Personal Information Retentacle Collects
Personal information is information about an identifiable individual, such as your name, address, telephone number, or email address (“Personal Information”). We collect some Personal Information when you voluntarily provide it through the Retentacle Platform, contact us through e-mail, telephone, mail, or other correspondence, or when you provide it to us through other means.
For example, when you register to use the Retentacle Platform we collect the following for the creation of the account:
We may also collect information when you use the Retentacle Platform, for example, when you choose to use a specific element of the Retentacle Platform that requests your Personal Information for a disclosed purpose, when you upload or access a receipt, or when you otherwise provide us with Personal Information. Information we collect in this manner may include:
Certain features and/or portions of the Retentacle Platform may be password-protected and may require you to provide a username and password in order to obtain access. When registering to use any such features and/or portions of the Retentacle Platform, you agree: (i) that you will provide complete and accurate information about yourself; and (ii) to update such information if it changes. In the event that you do not provide or update such information, or if we have reasonable grounds to suspect that you have not provided or updated such information, we shall have the right, in our sole and absolute discretion, to disable your username and/or password and prevent you from using the Retentacle Platform, or any features or portions of the Retentacle Platform. You agree to be responsible for: (a) the accuracy of all information that you provide to us; (b) maintaining the confidentiality and security of any passwords or other account identifiers that you choose or that are otherwise assigned to you; and (c) all activities that occur under such password(s) or account(s). It is your responsibility to keep your username and any password that you register or that is provided to you confidential and secure. In the event that your username or password is used without your consent or that you discover any other breach of security, you agree to promptly notify us. We are not responsible for your failure to comply with this clause, or for any delay in shutting down your account after you have reported a breach of security to us. You are solely responsible for any and all activities which occur under your account.
How Retentacle Collects Information Through Technological Means
When you visit or use the Retentacle Platform, we may collect information that is automatically sent to us by your web browser, device or your internet service provider. This information may include the type of browser or device you use, which pages or portions of the Retentacle Platform you view or use, and the files or services you request or use. We use this information to better understand how visitors use the Retentacle Platform, and to improve the Retentacle Platform, and our products and services, including to develop new ones. We use this information in the aggregate, and do not link it to your Personal Information. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this.
To enhance your experience using the Retentacle Platform, we may use a feature on your browser called a “cookie” account token, and/or other similar devices. Cookies are small files that your web browser places on your device hard drive. They are used for a variety of reasons, such as tracking information you have previously entered so you do not have to re-enter it. Your browser may give you the option to reject cookies. However, setting your browser to reject cookies generally hinders the browser’s performance and will adversely affect your experience while using the Retentacle Platform.
How Retentacle Uses and Discloses Personal Information
If you have provided us with your Personal Information, but later decide you no longer want us to send you any information from us, you may unsubscribe by using the unsubscribe message in our commercial communications. If you have agreed to receive commercial communications from a participating retailer, you may unsubscribe from further commercial communications from that retailer using any unsubscribe message in such commercial communications. Retentacle is not able to control the unsubscribe function for any third-party retailer.
We may share non-Personal Information, including aggregated user statistics and analytical statistics, with third parties in our discretion. For instance, we may de-identify data such that it no longer identifies you or any other person. Such de-identified information is not Personal Information, and we may use and/or share it, including via sale or license, freely. For example, we may create aggregated anonymous information and analysis, including product sales statistics, sales values, by brand, store, region, and demographic information, and share this information with third parties.
We may transfer your Personal Information to third party service providers that assist us with carrying out these purposes. For example, we may use a data processing contractor to operate computer systems on our behalf.
We reserve the right to transfer any Personal Information we have about you in the event that we merge with or are acquired by a third party or should any such transaction be proposed. We may also use, or disclose your Personal Information to third parties, if we have reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter; or (iv) to protect our rights, safety or property. Lastly, we may disclose your Personal Information for any other purpose to which you consent.
Personal Information collected online may also be combined with information you have provided to Retentacle through other sources such as over the telephone.
How we Protect Personal Information
The security of your Personal Information is important to us. We protect your Personal Information by maintaining physical, organizational, and technological safeguards intended to help protect against unauthorized use, disclosure or access. Personal Information may only be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law. We manage the Personal Information we collect from our offices in Toronto, Ontario.
Although we have taken measures to help protect the Retentacle Platform, computer systems and any Personal Information that we have collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.
Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the Personal Information.
Account Deletion and Information Retention
We retain Personal Information that we collect as long as reasonably necessary to fulfill the purposes for which it was collected or to meet any legal requirements. We destroy Personal Information or render it identifiable when it is no longer needed for the purposes for which it was collected.
You have the option to delete your account from the Retentacle Platform. If you do, your account will be deactivated for a period of 48 hours. If you do not reactivate your account within this 48-hour period, your account, and the receipts and personal information associated with it, will be deleted. For greater certainty, we are not required to delete anonymous, de-identified information including aggregated demographic information (including the user’s gender, age, and postal code) and information on receipts (including retailer, location, date, products, price etc.) that may have been prepared using your information.
Access and Rectification
You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to Retentacle and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact information provided below. We will use reasonable efforts to comply with your request; however, in some cases we may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your Personal Information.
Children and Parents
Retentacle does not knowingly collect Personal Information from children under 18. If a child has already provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information.
Third Party Websites
How to Contact Us
Please advise us by contacting our Privacy Officer by writing to: 525 Pine Ridge Rd., Pickering, Ontario L1W 2M6 You may contact us via email at: email@example.com.